Use of Ozone NAAQS to Control CO2 Emissions
In the March 18, 2021 Opinion Section of the Wall Street Journal, there is an article entitled “Biden’s ‘BackDoor ‘ Climate Plan”. This article describes how the Biden Administration may attempt to control CO2 emissions.
Writing legislation to directly control CO2 emissions has proven difficult, because CO2 is not a “criteria” pollutant. However, use of existing laws could possibly result in control of CO2. The article describes a CO2 reduction strategy using the ozone National Ambient Air Quality Standard (NAAQS).
Ozone is not emitted in significant quantities by vehicles or industry. However, nitrogen oxides are a precursor to the formation of ozone in the atmosphere. Reduction of nitrogen oxide emissions therefore results in lower ambient ozone concentrations to help meet a lower standard.
Nitrogen oxide emissions mainly result from combustion of carbon-based fuels in industry and in vehicles. This combustion also results in significant CO2 emissions. Burning 1 million cubic feet of natural gas results in 100 pounds of nitrogen oxides and 120,000 pounds of CO2. Therefore, reducing nitrogen oxide emissions from combustion to meet the ozone standard would also result in a significant reduction of CO2 emissions.
But what is the cost of this strategy? The current ozone NAAQS of 70 parts ozone per billion parts air is very close to the actual ozone concentration in many parts of the country. If lowered further, say to 60 parts per billion, many states would have areas that do not meet the new standard. As an example, every county in Tennessee that has an ozone monitor measures concentrations exceeding 60 parts per billion. Much of Tennessee would become non-attainment of the NAAQS. A similar condition is true for many other states.
A non-attainment area is subject to new air permit regulations designed to bring the area into attainment. Industry must install the highest level of emission controls and obtain emission offsets for new modifications. These costs can often push industry expansion elsewhere. United States industry would be thrown into an emergency fire drill to reduce combustion. And this when the vast majority of the country has ambient air concentrations of nitrogen oxides and ozone that EPA has declared safe for citizens to breath.
Motive force for vehicles is already on a path towards electric motors and batteries, but how fast can this switch be accomplished?
These questions are important considerations, and the answers should be determined before lowering the ozone standard for the purposes of CO2 reduction.
-Lem Stevens
Lem@StevensEnvironmental.com